United Kingdom Upper Tribunal (Tax and Chancery Chamber)

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You are here: BAILII >> Databases >> United Kingdom Upper Tribunal (Tax and Chancery Chamber) >> Ingenious Games LLP and Others and Revenue and Customs: [2019] UKUT 226 (TCC) (26 July 2019)
URL: http://www.bailii.org/uk/cases/UKUT/TCC/2019/226.html
Cite as: [2019] UKUT 226 (TCC), [2019] STI 1466, [2019] STC 1851, [2019] BTC 521

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Ingenious Games LLP and Others and Revenue and Customs: [2019] UKUT 226 (TCC) (26 July 2019)

INCOME TAX AND CORPORATION TAX -- LLPs established to carry on activities relating to the production of films and games - individual members of the LLPs making capital contributions for membership - funding also coming from commissioning distributor - Whether activities carried on by the LLPs constituted a trade - Whether activities of the LLPs carried on with a view to profit - Whether expenditure incurred by the LLPs equal to 100% of production budget of film or game - Whether expenditure incurred wholly or exclusively for purposes of LLPs trade - Whether LLPs accounts compiled in accordance with generally accepted accounting practice - Whether LLPs expenditure on film and games rights was capital expenditure for tax purposes - Income Tax (Trading and Other Income) Act 2005, ss 25, 26, 33, 34, 863 - Corporation Tax Act 2009 ss 46, 47, 53, 54, 1262, 1273.

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